M/S STANDARD FROZEN FOODS EXPORTS PVT LTD,HAPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CC-II, KANPUR

In the result, all the appeals are allowed

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

90,000/- on a account of unsecured loan us. 68 of the Income Tax Act, 1961. 6. That the Ld. CIT (A) has erred in confirming disallowance on account of interest on unsecured loan of Rs.1,71,382/-. 7. That the assessment completed by learned assessing officer is arbitrary, prejudicial and unlawful. 8. That the learned assessing officer has erred

SACHIN VERMA,HAPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE - II, KANPUR

In the result, all the appeals are allowed

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

90,000/- on a account of unsecured loan us. 68 of the Income Tax Act, 1961. 6. That the Ld. CIT (A) has erred in confirming disallowance on account of interest on unsecured loan of Rs.1,71,382/-. 7. That the assessment completed by learned assessing officer is arbitrary, prejudicial and unlawful. 8. That the learned assessing officer has erred

VINAI SHUKLA,LUCKNOW vs. ACIT-1, LUCKNOW NEW, LUCKNOW

In the result, the appeal of the assessee is partly allowed

Bench: Shri Kul Bharat & Shri Nikhil Choudharyआयकर अपील सं/ Ita No.624/Lkw/2024 ननिाारण वर्ा/ Assessment Year: 2017-18 Vinai Shukla V. Acit-1, Lucknow New 2/280, Vikas Khand Gomti Lucknow Nagar, Lucknow-226010. Pratyaksh Kar Bhawan, Lucknow-226001. Pan:Asnps3558C अपीलार्थी/(Appellant) प्रत्यर्थी/(Respondent) अपीलार्थी कक और से/Appellant By: Ms Shweta Mittal, Ca प्रत्यर्थी कक और से /Respondent By: Shri Prajesh Srivastava, Sr. Dr सुनवाई कक तारीख / Date Of Hearing: 21 08 2025 घोर्णा कक तारीख/ Date Of 12 09 2025 Pronouncement: आदेश / O R D E R

reassessment shall be completed in accordance with the provisions of this section as it stood immediately before its substitution by the Finance Act, 2016 (28 of 2016). Explanation 1.—For the purposes of this section, in computing the period of limitation— (i)the time taken in reopening the whole or any part of the proceeding or in giving an opportunity

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, BAREILLY, BAREILLY vs. ANKUR ANAND, BAREILLY

Appeals of the Department stand dismissed

Bench: Shri Sudhanshu Srivastava & Shri Nikhil Choudharyit(Ss) A Nos.336 & 337/Lkw/2025 Assessment Years: 2014-15 & 2015-16 Acit, Central Circle, Bareilly Vs. Ankur Anand Kamla Nehru Marg, Civil Lines, 148 Civil Lines, Bareilly, Bareilly, Bareilly-243001. Bareilly-243001. Tan/Pan:Agppa4219C (Appellant) (Respondent) It(Ss)A No.334/Lkw/2025 Assessment Year:2015-16 Acit, Central Circle, Bareilly Vs. Mohit Anand Kamla Nehru Marg, Civil Lines, 148 Civil Lines, Bareilly, Bareilly, Bareilly-243001. Bareilly-243001. Tan/Pan:Abupa3002H (Appellant) (Respondent)

90 taxmann.com 14 7/ 146 SCL 163. wherein the Hon’ble Apex Court has held that abnormal difference between the prices at which the trades were executed without corresponding effect on the price of the underlying security, shows that the option in which the party traded was not in demand in the market and that it was unusual that

ASSISTANT COMMISIONER OF INCOME TAX, CENTRAL CIRCLE, BAREILLY, BAREILLY vs. MOHIT ANAND, BAREILLY

Appeals of the Department stand dismissed

Bench: Shri Sudhanshu Srivastava & Shri Nikhil Choudharyit(Ss) A Nos.336 & 337/Lkw/2025 Assessment Years: 2014-15 & 2015-16 Acit, Central Circle, Bareilly Vs. Ankur Anand Kamla Nehru Marg, Civil Lines, 148 Civil Lines, Bareilly, Bareilly, Bareilly-243001. Bareilly-243001. Tan/Pan:Agppa4219C (Appellant) (Respondent) It(Ss)A No.334/Lkw/2025 Assessment Year:2015-16 Acit, Central Circle, Bareilly Vs. Mohit Anand Kamla Nehru Marg, Civil Lines, 148 Civil Lines, Bareilly, Bareilly, Bareilly-243001. Bareilly-243001. Tan/Pan:Abupa3002H (Appellant) (Respondent)

90 taxmann.com 14 7/ 146 SCL 163. wherein the Hon’ble Apex Court has held that abnormal difference between the prices at which the trades were executed without corresponding effect on the price of the underlying security, shows that the option in which the party traded was not in demand in the market and that it was unusual that

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, BAREILLY, BAREILLY vs. ANKUR ANAND, BAREILLY

Appeals of the Department stand dismissed

Bench: Shri Sudhanshu Srivastava & Shri Nikhil Choudharyit(Ss) A Nos.336 & 337/Lkw/2025 Assessment Years: 2014-15 & 2015-16 Acit, Central Circle, Bareilly Vs. Ankur Anand Kamla Nehru Marg, Civil Lines, 148 Civil Lines, Bareilly, Bareilly, Bareilly-243001. Bareilly-243001. Tan/Pan:Agppa4219C (Appellant) (Respondent) It(Ss)A No.334/Lkw/2025 Assessment Year:2015-16 Acit, Central Circle, Bareilly Vs. Mohit Anand Kamla Nehru Marg, Civil Lines, 148 Civil Lines, Bareilly, Bareilly, Bareilly-243001. Bareilly-243001. Tan/Pan:Abupa3002H (Appellant) (Respondent)

90 taxmann.com 14 7/ 146 SCL 163. wherein the Hon’ble Apex Court has held that abnormal difference between the prices at which the trades were executed without corresponding effect on the price of the underlying security, shows that the option in which the party traded was not in demand in the market and that it was unusual that

ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-1, BAREILLY vs. WAVE DISTILLERIES AND BREWERIES LIMITED, BAREILLY

Appeals of the Department stand dismissed

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudhary

90,13,100/- and tax was paid on the deemed total income of Rs.36,12,49,703/- as per the provisions of section 115JB of the Income Tax Act, 1961 (hereinafter called “the Act’). The case of the assessee was reopened by issuing notice dated 27.03.2021 under section 148 of the Act. For the sake of ready reference, the reasons

BHAWANI DEVELOPERS,LUCKNOW vs. INCOME TAX OFFICER-4(1), LUCKNOW-NEW, LUCKNOW-NEW

Appeal is disposed of in accordance with the aforesaid\ndirections

90,879/- as against total claim of Rs.\n86,26,860/-. The assessee, therefore failed to establish the remaining expenditure of Rs.\n24,35,981/- with corroborative documentary evidence. Hence, an amount of Rs.24,35,981/-\nrepresenting expenditure on account of material purchase for fencing work debited to profit\nand loss account are hereby disallowed and added to the total

RAKESH KUMAR PANDEY,GONDA vs. DCIT/ACIT(CENTRAL)-2, LUCKNOW

Reassessment Proceeding.\ndt. 05.09.2023, 08.02.2024, 11.03.2024, 16.03.2024,\n15.03.2024\n6. Original Assessment Order u/s 143(3) dt. 23.04.2021 and\nCIT(A) order u/s 250 dt. 25.06.2024\n7. Assessment Order u/s 147 dt. 28.03.2024\n8. Copy of Form-35\n9. Copy of Replies filed before CIT(A)-3, Lucknow dt.\n07.01.2025\n10. Copy of CIT(A)-3, Lucknow Order

ACIT, CENTRAL CIRCLE-II, LUCKNOW, LUCKNOW vs. RAKESH KUMAR PANDEY, GONDA U.P.

In the result, the outcome of the appeals and Cross Objections are as under:

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

reassessment proceeding covered by provision of section 147 to 151 where time for issuance of notice u/s 143(2) was left. Since the case of the assessee has already been considered as search case by Revenue in AY 2019-20 & AY 2020-21 while issuing notice u/s 148 directly without compliance of u/s 148A proceedings therefore

RAKESH KUMAR PANDEY,GONDA vs. DCIT/ACIT (CENTRAL)-2, LUCKNOW

In the result, the outcome of the appeals and Cross Objections are as under:

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

reassessment proceeding covered by provision of section 147 to 151 where time for issuance of notice u/s 143(2) was left. Since the case of the assessee has already been considered as search case by Revenue in AY 2019-20 & AY 2020-21 while issuing notice u/s 148 directly without compliance of u/s 148A proceedings therefore

RAKESH KUMAR PANDEY,GONDA vs. DCIT/ACIT (CENTRAL)-2, LUCKNOW

In the result, the outcome of the appeals and Cross Objections are as under:

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

reassessment proceeding covered by provision of section 147 to 151 where time for issuance of notice u/s 143(2) was left. Since the case of the assessee has already been considered as search case by Revenue in AY 2019-20 & AY 2020-21 while issuing notice u/s 148 directly without compliance of u/s 148A proceedings therefore

VIKAS JAIN,KANPUR vs. ACIT-CC 2(1)(1), KANPUR

In the result, the appeal of the assessee is partly allowed

Bench: Sh. Kul Bharat & Sh. Nikhil Choudharya.Y. 2015-16 Vikas Jain, Vs. The Acit, H-2/1, Kidwai Nagar, Kanpur- Circle 2(1)(1), Kanpur 208001 208006 Pan: Abqpj8049R (Appellant) (Respondent) Assessee By: Sh. Rakesh Garg, Adv Revenue By: Sh. Amit Kumar, Dr Date Of Hearing: 07.10.2025 Date Of Pronouncement: 31.12.2025 O R D E R Per Nikhil Choudhary, A.M.: This Is An Appeal Filed By The Assessee Against The Orders Of The Ld. Cit(A), Nfac On 17.05.2024 Wherein The Ld. Cit(A) Has Dismissed The Appeal Of The Assessee Against The Order Passed By The Ld. Assessing Officer Under Section 147 R.W.S. 143(3) For The A.Y. 2015-16 On 27.12.2018. The Grounds Of Appeal Are As Under:- “01. Because There Being No Reason To Believe, Far From There Being Any Material To Form Reasons To Believe, The Proceedings Initiated Right From Issue Of Notice U/S. 148 & The Re-Assessment Framed Thereof Are All Without Jurisdiction Bad In Law, The Order Passed Be Quashed. 02. Because The So-Called Reasons Having Been Recorded Applying Explanation 2(A) To Section 147, Of The Act Which Not Being Applicable, The Very Reason To Believe Being Contrary To The Mandate Of The Section, The Proceedings- Initiated U/S 148, The Reassessment Framed Are All Contrary To The Provisions Of Law, Be Quashed. 03. Because The Approval Given By The Competent Authority U/S 151, Being Mechanical In Nature Without Verification Of Facts, The Notice Issued U/S 148 & The Reassessment Framed Thereafter Be Quashed.

reassessment framed thereafter be quashed. 1 Vikas Jain A.Y. 2015-16 04. Because the NFAC has erred on facts and in law in upholding the addition of Rs.21,12,500/- u/s 50C of the Act which addition is contrary to facts, bad in law, be deleted. 05. Because the NFAC has failed to appreciate the facts and circumstances

SHRI VINAY PRATAP SINGH,LUCKNOW vs. ASTT. COMMISSIONER OF INCOME TAX, LUCKNOW

In the result, the appeal of the assessee is partly allowed

Bench: SH. SUDHANSHU SRIVASTAVA, JUDICIAL MEMBER AND SH. NIKHIL CHOUDHARY (Accountant Member)

90,81,650/- in A/c No. 07222020001730 with HDFC Bank, Hazratganj, Lucknow e. Rs. 33,000/- in A/c No. 84822200014042 with Syndicate Bank, Indira Nagar, Lucknow In response to a query regarding the source of the bank accounts, the assessee submitted a cash flow statement showing month-wise cash sale, but the ld. AO records that no proof of sale

HORIZON DWELLINGS PRIVATE LIMITED,BAREILLY vs. PCIT, BAREILLY

In the result, the appeal of the assessee is allowed for statistical purposes

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguriahorizon Dwellings Pvt Ltd V. Pcit, Bareilly, Navjeevan Appartments, Income Tax Department, Opposite Parag Factory, Bareilly (Up)-243001. Badaun Road, Kargaina, Bareilly-243001. Pan:Aacch6839F (Appellant) (Respondent) Appellant By: Shri Rakesh Garg, Adv. Respondent By: Shri Sunil Kumar Rajwanshi, Addl. Cit(Dr) O R D E R

reassessment proceedings, since view taken by him was one of possible views, impugned revisional order passed under section 263 was to be set aside CIT Vs. Honda Siel Power Products Ltd. [(2010) 6 TAXMANN 15] In cases where the Assessing Officer adopts one of the courses permissible in law or where two views are possible and the Income-tax Officer

INCOME TAX OFFICER- 6(2), LUCKNOW vs. M/S. STATUS VYAPAAR PVT. LTD., LUCKNOW

In the result, the appeal of the Revenue is dismissed

90,00,000/- earned\nundisclosed income through such company (appellant)surrendered before\nHon'ble ITSC and said application is accepted and matter is at final stage\nin the assessment year 2012-13, the management of the company was not\nwith the Mahesh Chandra Agarwal group. However, in relevant year only\nloan were given amounting Rs.3,50,00,000/from appellant

SH. SUKHVINDER SINGH,KANPUR vs. PR CIT, CENTRAL, KANPUR

In the result, both appeals filed by the assessee are allowed for statistical purposes

Bench: Shri Kul Bharat & Shri Anadee Nath Misshra

90,400/- as against declared investment of Rs. 9,50,500/- therefore an addition of Rs 3,39,900/- has been made to the total income of the assessee on account of unexplained investment AY 2012-13.” (B.2) Subsequently, the Ld. PCIT started proceedings u/s 263 of the Act. Vide notice dated 27.02.2020, the Ld. PCIT was of the view

SH. SUKHVINDER SINGH,KANPUR vs. PR CIT, CENTRAL, KANPUR

In the result, both appeals filed by the assessee are allowed for statistical purposes

90,400/- as against declared investment of Rs.9,50,500/- therefore an addition of Rs 3,39,900/- has been made to the total income of the assessee on account of unexplained investment AY 2012-13.\"\n\n(B.2) Subsequently, the Ld. PCIT started proceedings u/s 263 of the Act. Vide notice dated 27.02.2020, the Ld. PCIT